FCPAméricas Blog

Archive for Foreign Official/Instrumentality category:

New Pemex Corruption Risks

Over the years, companies providing goods and services to Petróleos Mexicanos (Pemex), Mexico’s state-owned oil & gas company, have faced numerous FCPA risks. Pemex is considered an “instrumentality” of a foreign government under the FCPA since it is controlled by the Mexican Government. As a result, its officials are considered “foreign officials” under the FCPA, […]

Author: Matteson Ellis

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Healthcare Compliance Risks in Latin America

In the last decade, there have been a number of FCPA enforcement actions in the healthcare sector. This post discusses some of the challenges faced by companies that operate in Latin America in this industry and ways to mitigate risks. While the challenges discussed are true regardless of the region, they are particularly relevant in […]

Author: Carlos Ayres

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Move Over “Foreign Official”: There’s a More Important FCPA Debate

A lot has been written about the definition of government “instrumentality” under the FCPA. That definition is important because it helps define the scope of the term “foreign official” for purposes of foreign bribery offenses. The May 2014 ruling by the U.S. Court of Appeals for the Eleventh Circuit in United States v. Esquenazi helped […]

Author: Matteson Ellis

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The Tangible and Intangible Drivers of FCPA Risk in Venezuela Today

Hugo Chavez came to power in Venezuela in 1999, riding a wave of dissatisfaction with the corrupt oligarchic elite that had governed the country for years. Despite his promise, corruption in Venezuela is still rampant, and might have gotten worse. Chavez’s successor, President Nicolas Maduro, just last week approved a set of strengthened anti-corruption laws […]

Author: Matteson Ellis

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Five Ways that Concentration of Wealth and Power Affects Corruption Risk in Latin America

The following post is a modified excerpt from TRACE’s recently published 2014 How To Pay a Bribe book, available here for purchase. Latin America is known as one of the most economically unequal regions of the world. By 2010, according to United Nations Development Program data, the region had 18 of the 25 countries in […]

Author: Matteson Ellis

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